John S. Gurich v. Commissioner of Internal Revenue

ALDRICH, Circuit Judge.

In July 1950, petitioners Bessette and Gurich (who, with their wives, are taxpayer-petitioners herein) created a voluntary declaration of trust naming themselves trustees, and conveyed to themselves certain property, principally real estate. They reserved to themselves the broadest possible powers of investment, including the right “to purchase or lease any part of the trust property or premises, any rule of equity to the contrary notwithstanding.” By this last we take it they were permitted to deal individually with themselves. The beneficiaries, whose names were set…